Practice-Transcript-6_Redacted_F116

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1
THE COURT: Did you want to go off the record and
2 answer it?
3 MR. MATES: So during opening hours and, Your
4 Honor, is correct. During opening hours -- remember the
5 security guards have to be there from either 4:00 in the
6 morning until 1:00 in the evening except for special
7 events and things like that because things may be
8 happening. But generally speaking, it's four to one.
9 When it's opening time, they do have to do an inspection
10 to see if there are any -- and they are supposed to
11 contractually, by their post orders, walk around the
12 entire facility. That's the actual building itself, to
13 make sure there are no vagrants there, pick up garbage,
14 things like that and open because there is an iron gate
15 that comes down when it's closed.
16 They open up the gate and they do have some
17 responsibilities beyond the actual opening and the same
18 thing with closing. At closing time, they make sure that
19 no one is around. They get rid of all the vagrants and
20 all of that and they do walk around in the grassy areas
21 and things like that. But during the time when this man
22 was shot, that is not his responsibility. Their
23 responsibility is to be within that building. Now, the
24 county could have asked us and contracted for us to patrol
25 the entire area. They could have done that, but they